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正常交易原则及其方法并非管制资本弱化行为的有效方法。为提高税法的确定性和适用效率,我国应该利用“两税合一”的契机,建立和完善以固定比例法为主、正常交易原则为辅的资本弱化税制。新的资本弱化税制应无差别地适用于境内和境外交易。在采用固定比例法设计中国的资本弱化税制时,应结合中国的国情实际,一方面要尽可能地使其接近正常交易原则,另一方面也要确保该方法的灵活性。
The principle of normal trading and its methods are not effective ways of controlling the weakening of capital. In order to improve the certainty and efficiency of the tax law, our country should make use of the opportunity of “combining two taxes and one tax” to establish and perfect the capital weakening tax system which is mainly supplemented by the fixed proportion method and complemented by the normal trading principle. The new capital weakening tax system should apply indifferently to domestic and foreign transactions. In designing China’s capital weakening tax system with a fixed percentage approach, we should combine China’s national conditions with reality, on the one hand, to bring it as close to normal trading principles as possible and, on the other hand, to ensure the flexibility of the approach.